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Keeping CCPA compliant with Facebook’s limited data use

August 3, 2020

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The CCPA enforcement date of July 1 has recently passed, but there are still areas of the regulation that businesses need clarity on. One particular need for clarity surrounds data-sharing relationships, such as those that exist between advertisers and Facebook. Facebook has recently announced the launch of a Limited Data Use (LDU) feature to help businesses work towards their CCPA compliance goals. 

The LDU feature will allow businesses to exercise more control over how their data is used in Facebook’s systems. This new feature will most significantly affect Facebook ad buyers and marketing performance. 

Between July 1 and July 31, the LDU is automatically enabled on all Facebook business accounts. From July 31 onwards businesses will be required to update their pixel to include an LDU parameter. 

In short, the LDU feature works by automatically detecting if a user is a California resident and then limiting the way that their user data can be stored and processed. 

CCPA background  

The LDU is designed to help business with CCPA compliance, so below is a brief overview of the relevant CCPA requirements: 

  • Information being collected must be transparent about what data they collect, the purpose for it, and any third parties it may be shared with  
  • A business must delete the data if it’s requested by the user   
  • Consumers can opt-out of their data being sold through a “Do Not Sell” button or link on a website   

Businesses that target residents of California must comply with the CCPA. So, if your business markets to California residents on Facebook you must ensure compliance or your business may face liability and potential penalties. 

Facebook’s LDU as part of your CCPA compliance

By using Facebook LDU, advertisers are able to specify which data should be subject to the protections of the CCPA. See the specific ways that user data will be limited under Facebook’s list of state-specific terms here

Detecting if a user resides in California is done through a modification to the Facebook PageView pixel. Within the Facebook pixel, ‘dataProcessingOptions’ must be included. The string will allow an advertiser to control whether they are identifying California residents or if Facebook should handle the auto-identification. 

The most notable consequence here is that the LDU may well have a significant impact on overall performance targeting for California residents. Facebook notes that “When Limited Data Use is enabled, businesses may notice an impact on campaign performance and effectiveness, and retargeting and measurement capabilities will be limited.” 

What should be done before July 31?

The responsibility for assessing processes and taking decisive action still sits with businesses. There are two ways of approaching Facebook’s new LDU feature:

Approach 1: Implement a consent management platform that gives users a clear choice to opt-out of tracking. This would mean that the LDU would only need to be enabled for users who opted out, which would stop the Facebook pixel from firing. By taking this approach a business can still use behavior-based and re-targeted ads if California users do not opt-out.

Approach 2: Do not offer an explicit opt-out and enable the LDU to limit the data of all identified California residents. This approach has the downside that all California residents will be excluded from re-marketing, meaning that marketing performance will likely take a significant hit.   

The important thing here is timing, whichever route your business takes, the LDU update on your Facebook pixel must be actioned before August 1. 

For more information on how OneTrust can help, request a demo today. 


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Customer Story

Consent & Preferences

Progress Software

See how Progress Software uses OneTrust Consent and Preferences and A/B testing solutions to streamline their process and increase opt-in rates. 

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Customer Story

GRC & Security Assurance

ORTEC

See how ORTEC tackles regulatory gaps, engages the business to keep risk data current, and takes an automated approach audit management with OneTrust.

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Customer Story

Consent & Preferences

Wipro

See how a partnership betweenOneTrust and global cybersecurity leader Wipro helped an American retail chain become CCPA compliant.

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Customer Story

Privacy & Data Governance

ResMed

Learn how ResMed creates a healthy global privacy program and stays up to date with new regulations with OneTrust privacy management software.

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Consentimiento de cookies | Solicitar demostración | OneTrust

Solicita una demostración del módulo Consentimiento de cookies de OneTrust y aprende cómo bloquear las cookies en cuestión de minutos con nuestra tecnología de cookies fácil de usar.

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Consentement aux cookies | Demander une démo | OneTrust

Demandez une démonstration de la solution de consentement aux cookies OneTrust et découvrez comment bloquer les cookies en quelques minutes grâce à notre technologie ultra simplifiée.

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Cookie Consent | Demo anfordern | OneTrust

Fordern Sie eine Demo von OneTrust Cookie Consent an und erfahren Sie, wie Sie mit unserer stark vereinfachten Cookie-Technologie Cookies in wenigen Minuten blockieren können.

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Consentimento de Cookies | Solicitar Demonstração | OneTrust

Solicite uma demonstração da solução de Consentimento de Cookies OneTrust e veja como bloquear cookies em poucos minutos com nossa tecnologia extremamente simples.

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Consenso all'uso dei cookie | Richiedi una demo | OneTrust

Richiedi una demo del Consenso all'uso dei cookie OneTrust e scopri come bloccare i cookie in pochi minuti con la nostra tecnologia estremamente semplificata.

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Consenso all'uso dei cookie | Richiedi una demo | OneTrust

Richiedi una demo del Consenso all'uso dei cookie OneTrust e scopri come bloccare i cookie in pochi minuti con la nostra tecnologia estremamente semplificata.

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Cookie Consent | Demo anfordern | OneTrust

Fordern Sie eine Demo von OneTrust Cookie Consent an und erfahren Sie, wie Sie mit unserer stark vereinfachten Cookie-Technologie Cookies in wenigen Minuten blockieren können.

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Consentimento de Cookies | Solicitar Demonstração | OneTrust

Solicite uma demonstração da solução de Consentimento de Cookies OneTrust e veja como bloquear cookies em poucos minutos com nossa tecnologia extremamente simples.

Learn more